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SPON Web Privacy Policy

Privacy Policy Statement:

Your trust is vital to us. Recognizing the significance of personal information, we commit to upholding the security and protection of your personal data as per legal requirements. Given this importance, the privacy policy ("this policy") is established by SPON Communications Co., LTD (hereinafter referred to as "SPON", "we", or "our") to define the foundation upon which we handle your personal data.

Before using the SPON official website, it's essential for you to carefully read and fully comprehend this policy. You may only use our products or services after understanding and agreeing to this policy's terms. By beginning to use the SPON official website, it indicates your full understanding and agreement to all the terms of this policy.

In essence, the statement emphasizes the importance of users' trust, their commitment to protecting user data, and the necessity for users to understand and agree to the policy before using the website or its services. 

If you lack the legal capacity due to age or other factors, please review and decide on this agreement with the guidance of your legal guardian. For users outside of mainland China, ensure your actions and use of this service align with the regulations of your respective country or region.
SPON: Denotes SPON Communications Co., LTD and any associated entities involved in its service operations.
SPON Web Platform Members: Refers to individual users, businesses, or groups that sign up, access, and utilize the SPON web platform (inclusive of platforms like Support, Download, Maintenance Oversight System, License platform, and more).
The previously mentioned "SPON Web Platform Members" are often addressed as "members" and frequently referred to as "you" within this document. If you engage with different offerings managed by SPON or its partners and want insight into the data collection and usage process, kindly review the privacy guidelines of that specific offering.
Product: Denotes the digital and physical solutions that we market or provide to SPON's clientele. 
Service: Refers to any pre-sale or post-sale support and other product-related services under our purview, regardless of whether they are provided online or offline.

This Privacy Policy will help you understand the following:

1. How we collect and use your personal data.

2. How we share, transfer, and disclose your personal data.

3. How we protect your personal data.

4. The duration we retain your personal data.

5. How you can manage your personal data and your rights regarding your personal data.

6. How we handle children's personal data.

7. Third-party service providers.

8. Transfer and storage of your personal data.

9. Updates and notifications of this policy.

10. How to contact us. 

1. How We Manage Your Personal Data
1.1 Information Collection
Personal data encompasses details, whether stored electronically or in other formats, pertaining to an identifiable individual, excluding anonymized data. To offer our services, certain essential data is required. We collect only the data crucial for clear, legitimate purposes, ensuring no further unrelated processing. If you opt not to provide certain details, SPON might not be able to deliver some services or address specific issues.

Depending on the services you opt for, we might gather various types of information:
1.1.1 Information You Actively Provide
Depending on the services you select, we gather personal data you willingly provide while using those services.
Account Registration: When you create, modify, or log into your SPON website account, we collect data you offer, including username, company name, official company website, your job title, distributor company name for SPON products you've purchased, your region, country, city, account type selection (end-user or partner), and your set login password. We also collect your phone number and email address. The provided phone number and email address are utilized for registration, logging in, account linking, password recovery via verification codes, and serve as one of your designated contact methods with SPON for business notifications (like service updates, billing, business communication) and specified after-sales services (like troubleshooting).
Trial Applications: You can opt for trial applications. Once we receive your application, a dedicated representative will contact you. To use the trial application service, you'll need to provide your name, email, company, and contact number.

Connecting with SPON: If you wish to learn more or are interested in specific information, you can reach out to SPON. Should you choose to engage, we may gather data such as your name, phone number, email address, company name, region, as well as any specific requirements or feedback you provide.

License Application: The License system is used for applying for all SPON licenses. When utilizing the License system, we may collect data such as username, whether the License is unlocked, purpose (normal shipment, internal use), MAC address, version, model, validity period, reason for application, authorized company name, email, notes, device ID, license type, concurrent quantity, project name, project number, supported device count, K3 sales order number, K3 shipment order number, agency name, sales representative, attachments, status, approver, approval date, company name, region, country, role, account type, order number, business type, order type, objective, and submission date.

Maintenance Management: When using the Maintenance Management system, you may need to provide details such as recipient's name, contact number, detailed address, list of parts to be returned, work order type, courier company, shipment tracking number, problem description, attachments, and the assigned after-sales engineer.

Partner Application: To become a SPON partner (including SPON dealers, distributors, or channel partners), or to establish a similar relationship with SPON, you can complete an online application. Through the partner application, we may collect information such as your name, phone number, email, company name, province, city, and other relevant details.
1.1.2 Information Collected During Your Use of Our Services

Device and Network Information: When you use SPON products and services, we gather information about your device, such as IP address, type and version of the operating system, browser type and version, and account status.

Interaction History: This category of information is directly submitted to us when you use our website, products, or services, and interact with us. For instance, any information request you provide, including the search queries you enter or any issue or information you provide to get customer support, data uploaded for reporting issues, and communication records whether online, via phone, or email.

Subscription and Favorites Information: For example, when using the Support platform, you can choose the modules you want to subscribe to (products, knowledge base, new product UAT plans, user research, SPON notifications) and whether to set up email alerts (if you choose yes, you will receive email notifications for updates in the subscribed modules). If you find an article helpful, you can click on the "favorite" button, and the favorited articles can be found in the Personal Center - Favorites section.

Log Information: When you use the SPON official website, SPON will collect and store necessary log information, such as access time, page path visited, IP address, and event information (e.g., errors, crashes).
1.2 Use of Third-party Services
1.2.1 We might utilize Google Analytics, a web analysis service provided by Google.
We have no control over such third parties and cannot influence their privacy or personal data protection policies. Such third parties are not bound by this privacy policy. Before submitting personal information to any third party, please thoroughly review their privacy policy or terms of service.

1.3 Purposes for Using Your Personal Data:
1.3.1 Account Creation: You can choose to create an account on the SPON official website to better utilize our services. This account provides identity verification when using SPON product services, connects with you, and sends crucial notifications. We may send information or notices to your email, including but not limited to essential verification codes and necessary push notifications for service usage. For this purpose, the personal data used is information you must authorize us to have. If you refuse to provide the relevant information, you may be unable to use the product and/or service normally.

1.3.2 To Offer Basic Product or Service Functions: To provide you with the core features of a product or service, we need to gather information necessary for the purpose of the service. For instance, to offer maintenance services, we need to collect user names, email addresses, and purchased product information (including SN code and Mac addresses). For this purpose, the personal data used is information you must provide. If you decline to supply the corresponding data, you may not use the product and/or service as intended.

1.3.3 For Content Recommendations and Service Improvements: We might send marketing information to the contact details you provided, which includes but is not limited to news about SPON products, market activities, and promotional offers. If you prefer not to receive marketing information, you can opt out, unsubscribe from the notification, or contact us to unsubscribe.

1.3.4 To Respond to Your Interaction Requests: When you visit our website, participate in online or offline events, request modifications, or contact us about any issues or product details (such as providing technical support, offering feedback, inquiries, etc.), we need to gather your contact details and interaction information.

1.3.5 For internal purposes, such as data analysis, research, and developing statistics related to the usage of our products or services, aiming to improve our products or services further.
1.3.6 To perform operational analysis and assist users in resolving problems, we need to collect log information and terminal information necessary for operational maintenance to safeguard our products, services, and the security of our customers or users.

1.4 When providing you with business functionalities or specific services, we will collect, use, store, disclose, and protect your personal data in accordance with the stipulations of this policy. If we need to collect your personal data beyond the scope of this policy and the corresponding product or service terms, we will explain the range and purpose of data collection separately and only collect the necessary information for providing the respective service after obtaining your consent.

1.5 We ensure that your personal data is used only for essential business purposes. Internal management personnel will obtain only necessary information based on their role divisions. The personal data we collect will not exceed the information necessary to achieve the purpose of the product or service. The legal basis for such processing includes:
(i) Compliance with legal obligations,
(ii) Fulfillment of a contract,
(iii) Legitimate interests, and
(iv) Your consent.

2. How We Share, Transfer, and Disclose Your Personal Data

2.1 Except for the situations listed in 2.2, we will not share, provide, disclose, sell, rent, or trade your personal data with any unrelated third parties unless we have obtained your permission in advance. The exception is if such third parties and we provide services to you either independently or jointly; they will be prohibited from accessing all such data, including the data they could access previously, once the service is terminated.

2.2 We may disclose all or part of your personal data in the following circumstances, according to your wishes or the stipulations of the law:
a) With your prior consent, we may disclose your personal data to third parties.
b) If there are reasonable demands that necessitate the disclosure of your personal data, for instance, to comply with applicable laws, regulations, legal processes, or the mandatory requirements of relevant administrative and judicial authorities. 

3. How We Protect Your Personal Data

3.1 Your personal data security is of paramount importance to us. We provide corresponding safeguards for your information to prevent its loss, misuse, unauthorized access, or disclosure. We have taken appropriate technical and organizational measures to protect your personal data, preventing both internal and external unauthorized access, as well as preventing it from being misused, altered arbitrarily, or damaged.

Specifically, we have taken the following measures:
● Pseudonymization and encryption of personal data;
● Ensuring the confidentiality, integrity, availability, and resilience of processing systems and services;
● Timely recovery of personal data availability and access in the event of a physical or technical incident;
● Regular testing, assessment, and evaluation of the effectiveness of technical and organizational measures to ensure a secure processing procedure.

This means, for example:
● We use access control mechanisms to ensure that your personal data is accessible only through authorized access;
● We use encryption technologies (such as TLS, SSL) to ensure the confidentiality of personal data;
● We deploy protective mechanisms against system attacks;
● We strictly limit the scope of personnel accessing the information. Those with the right to access your personal data and can represent us are obligated to maintain the confidentiality of your personal data in accordance with their applicable codes of conduct and professional standards.

3.2 All accounts on the SPON official website have security protection features. Please take good care of your username and password information. Protect your personal data and only provide it to others when necessary. Use this product correctly and legally to prevent others from seizing the opportunity to obtain your information and communication content. Do not disclose details such as your account and password. SPON is not responsible for any information leakage due to sharing your password or account with others. If your account is accessed illegally, please notify us immediately. It's advisable to change your password frequently.

3.3 If there's a security incident, such as a data breach, we will activate our emergency response plan to prevent the security incident from expanding. In accordance with relevant laws and regulations, we will inform you through push notifications, emails, announcements, etc.

4. How Long We Retain Your Personal Data

We promise that the retention period for your user information will not exceed the maximum period required to achieve the purposes set out in this policy for the relevant user information category or to comply with applicable data protection laws. Moreover, we strive to promptly delete or anonymize any irrelevant or excessive data.

The criteria used to determine this retention period include:
- The duration of our ongoing relationship with you and the continuation of our provision of the SPON official website (for instance, as long as you hold an account with us or continue to use the SPON official website).
- Our legal obligations to retain data (for instance, some laws require us to keep your transaction records for a certain period before they can be deleted).
- Recommendations to retain this information due to our legal position (such as certain applicable laws regarding statute of limitations, disputes, or regulatory investigations).

4.1 We will store your user information securely only for the time necessary to achieve the purpose of the service or as mandated by laws and regulations. In accordance with the "Cybersecurity Law of the People's Republic of China," we will retain relevant web logs of your use of the official website for no less than 6 months.

4.2 In the following cases, we will stop retaining your user information:
4.2.1 When our product or service ceases operation, we will notify you in the form of push notifications, announcements, etc., and delete or anonymize your user information within a reasonable period unless otherwise stipulated by laws and regulations.
4.2.2 When you or your affiliated enterprise decide to stop using the enterprise management platform and notify SPON in writing, SPON will retrieve all accounts of you or your enterprise and delete the corresponding user information.
4.2.3 At your request, we will delete all or part of your user information.
To comply with investigative requests from relevant judicial authorities, user information required for subscription and use of services will be deleted 5 years after your last use of the SPON official website.
SPON does not retain user information of potential customers.
5. How You Manage Your Personal Data and Your Rights Concerning Your Personal Data

5.1 You should ensure that all personal data you submit is accurate and true. SPON endeavors to maintain the accuracy and completeness of personal data and promptly update such data. When required by applicable laws, you have the right to control your personal data in the following ways:
● You have the right to request us to inform you about any personal data we hold about you.
● If your personal data is inaccurate, incomplete, or processed unlawfully, you have the right to request us to update, correct, supplement, or restrict the processing of your personal data.
● To exercise related rights, please notify us via the following email address: Info@sponcomm.com. Typically, we will respond within 30 days, unless another timeframe is required by applicable law. Depending on the complexity of your request, we might extend this period by two more months. In such cases, we will inform you of the extension and its reasons within 30 days after receiving your request. For security reasons, you may need to submit a written request. If we have reasonable grounds to believe that such requests are fraudulent, unenforceable, or infringe on the privacy rights of others, we may refuse to process the request.

5.2 Where required by applicable law, you have the right to revoke your consent at any time. However, revoking consent will not affect the legality and validity of any processing we conducted based on your consent before the revocation. It also won't affect our processing of your personal data based on other appropriate lawful bases. Please note that depending on the scope for which you've authorized us to process information, this may result in you being unable to enjoy SPON's products or services.

6. How We Handle Children's Personal Data

Our products and services are not intended for children, and we do not intentionally collect personal data from children without the consent of their parents or guardians. If you discover that your child has provided personal data to us without your permission, please notify us via the following email address: Info@sponcomm.com. If you alert us, or if we find out that personal data has been collected from children, we will promptly delete this data.

7. Third-Party Service Providers

We may engage third-party service providers to help us implement the data processing discussed in this policy, including tasks like encoding and decoding processing, data storage, and data queries, among other things. Our service providers might include hosting/infrastructure/storage providers, payment service providers, analytics tool providers, customer support tool providers, marketing, and email providers. We prohibit third-party service providers from selling the data they receive from us and require them to use this data solely for the services SPON has asked them to provide, unless otherwise required by law. Beyond this, we do not allow any third party to collect, edit, sell, or disseminate your personal data by any means. 

8. Transfer of Your Personal Data

Due to SPON's global business operations, it means that the personal data SPON collects may come from various countries worldwide, and data processing might occur in different nations. The data protection laws in these countries/regions may differ. User information collected and generated by the SPON official website operating within the People's Republic of China will be stored on servers provided by Alibaba Cloud. Personal data collected and generated when operating outside the People's Republic of China will be stored on servers in the China. In this context, we will take measures to ensure that the data we collect is processed in accordance with this statement and applicable laws. For example, 
(i) signing data transfer agreements based on EU Model Clauses, and you can obtain a copy of the EU standard contractual clauses by [clicking here]. (ii) Formulating and adopting binding corporate rules, (iii) relying on exceptions defined by law (such as seeking your explicit consent), or (iv) adopting other measures deemed to provide adequate protection for your personal information.

9. Updates and Notifications of This Policy

SPON reserves the right to update or modify this policy from time to time. To comply with current laws or for other legitimate reasons, we may occasionally amend this policy. If this policy is amended, we will post the latest version of the privacy policy here, and the revised policy will take effect immediately from the date of publication. If we make substantive changes to this policy, resulting in a reduction or alteration of your rights under this policy, we will notify you before the changes take effect through email or other feasible means. We encourage you to review this policy periodically to get the latest information.

10. How to Contact Us

If you have any questions about this policy, or if you wish to exercise your rights to control your personal data, you can contact us through the following means.

SPON Communications Co., Ltd.

Registered Address: No. 70 Nantang Road, Lugu Street, High-tech Development Zone, Changsha City

Primary Business Address: No. 70 Nantang Road, Xiangjiang New District, Changsha City

Contact for Data Security Officer:
Phone Number: 86-731-85570190 
Email Address: Info@sponcomm.com